Russia-related General License 8H - Authorizing Transactions Related to Energy (October 25, 2023) [PDF includes all versions]

Date issued: Oct. 25 2023

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (388 words)

Notes:

1) Refer to comments to the following relevant FAQs: FAQ # 976, FAQ # 977, FAQ # 978, FAQ # 967, FAQ # 974, FAQ # 1010, FAQ # 1011 and FAQ # 1012.

2) Query: is the scope of the GL limited to transactions where the banks listed would process underlying authorized transactions, or also transactions in which, for example, the banks are investors in covered projects?

3) GL amended on 2-28-2022 to (i) add the reference to (i) add "the Central Bank of the Russian Federation," (ii) specify that the GL does not apply to transactions otherwise prohibited by Directive 1A Under Executive Order 14024, and (iii) add paragraph (c)(3) "[a]ny debit to an account on the...